To make an immediate recall...

For all other recalls and non-recall actions, go to Step 2 of the recall procedure.

This guidance on the Uniform Recall Procedure for Therapeutic Goods (URPTG) provides a consistent approach for undertaking recall and non-recall actions of therapeutic goods supplied, imported into or exported from Australia.

It replaces the Uniform Recall Procedure for Therapeutic Goods (2004) following public consultation.

The purpose of the URPTG is to assist the sponsors of therapeutic goods to conduct recalls and non-recall actions using a standardised systematic procedure.

It enables sponsors to respond efficiently and effectively to issues with a therapeutic good that has or may pose a risk to public health and safety.

Requirements of this procedure can also be applicable when the TGA orders an appropriate responsible entity to conduct a mandatory recall. Civil and criminal penalties apply if you do not comply with a mandatory recall.

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Why is there a new URPTG?

The URPTG has not been reviewed or updated since 2004. It was important to undertake an extensive stakeholder consultation process to review and update the procedure in order to ensure it is consistent with current regulatory 'best practice'.

When does the new URPTG take effect?

The new URPTG will be implemented and take effect on Monday 15 January 2018. The TGA has published the new URPTG in October 2017 so as to provide all stakeholders with a familiarisation period prior to its implementation.

What are the major changes to the URPTG?

While the fundamentals for undertaking a recall or non-recall action remain largely the same, in response to the consultation process, the new URPTG –

clarifies existing processes and clearly delineates the roles and responsibilities of the different parties who can be involved in recalls

introduces probability aspects as part of the recall classification process

introduces some new terminology; and

provides information about the legislative powers for mandating recalls.

More detailed explanations of these major changes to the URPTG are described below.

What are the different types of recall actions?

The URPTG now defines four (4) different types of recall actions. A recall action is conducted to remove therapeutic goods permanently from the market or from use when there are deficiencies or potential deficiencies in safety, quality, efficacy, performance or presentation. The four types of recall action are:

recall

product defect correction (replaces 'recall for product correction')

hazard alert

product defect alert.

Are there new types of recall actions?

Yes. The new terms are 'product defect correction' and 'product defect alert'; and these are defined below.

Minor amendments have also been made to the terms, 'recall' and 'hazard alert', but the overall meanings remain largely unchanged.

Do I still have to use the term 'Recall for product correction'?

Yes, but only up until 15 January 2018. When the new URPTG is implemented on this date, the term 'recall for product correction' will no longer be used to categorise recall actions. This term is being replaced by 'product defect correction'.

What are the different types of non-recall actions?

The URPTG still defines four (4) different types of non-recall actions which can be conducted if the therapeutic goods meet all specifications and standards; and there are no deficiencies in safety, quality, efficacy, performance or presentation of the goods. The four types of non-recall action are:

safety alert

product notification

quarantine

product withdrawal.

Are there new types of non-recall actions?

Yes. The new term is 'quarantine' which has replaced 'recovery' and is defined below.

Minor amendments have been made to the terms, 'safety alert', 'product notification' and 'product withdrawal', but the overall meanings remain largely unchanged.

'Failure mode' in relation to the recall of therapeutic goods, means how the failure will be presented.

'Failure rate' in relation to the recall of therapeutic goods, means the frequency with which the failure occurs for the affected stock.

'Product defect alert' means a type of recall action that raises awareness of concerns about safety, quality, efficacy or performance when discontinuation of treatment is considered riskier than continued use of the deficient product.

"A product defect correction is undertaken to correct a specific or potential deficiency. In some instances, the product can continue to be used if there is robust mitigation in place until a permanent correction has been implemented. Product defect correction includes:

the repair, modification, adjustment or re-labelling of therapeutic goods for reasons relating to deficiencies in the quality, safety, efficacy, performance or presentation

corrections involving a product's expiry date

updates or changes to any accessories, operating instructions or software."

'Quarantine' means a type of non-recall action in which the sponsor suspends further supply pending investigation of an issue or incident. The outcome of the investigation will determine further actions. A recall may occur after quarantine.

What else is new in the URPTG?

The new URPTG includes the following new features –

it is now presented in a 'web friendly' format which is easy to navigate

it now provides step-by-step instructions and supporting information for sponsors (and any other responsible entities) to follow when conducting a recall

it now clearly delineates the roles and responsibilities of the different parties who can be involved in a recall, including sponsors, manufacturers, wholesalers and distributors, exporters, health professionals, consumers, the TGA, state and territory recall coordinators and the Australian Competition and Consumer Commission (ACCC)

it provides greater clarification on the requirements for medical devices (including in-vitro diagnostic goods (IVDs), and

also includes a refinement of the information required to assess a recall action.

Are recalls still classified as Class I, II or III?

Yes, however, the definitions have been slightly changed to introduce probability aspects which will assist with assigning the appropriate risk classification, where 'risk' = 'severity' x 'probability'.

Are there any changes to the 'level of recall?

No. Recalls will still be classified as, either –

wholesale level

hospital level

retail level; or

consumer level.

Is the URPTG legally binding?

No. The URPTG is not underpinned by the therapeutic goods legislation or established as a legislative instrument. It is a long-standing guidance document and this latest version is now published following extensive public consultation.

If a responsible entity chooses not to follow the URPTG process, the Therapeutic Goods Act 1989 does provide powers for the Secretary to mandate the public notification and recall of therapeutic goods.

The Secretary may mandate recall action in relation to therapeutic goods for a range of reasons, including where the goods are unsafe, are of defective quality, for medical devices that do not comply with the essential principles, where the goods have been cancelled from the ARTG and so on.

In any case, requirements of the URPTG can be made applicable when the Secretary orders a responsible entity to conduct a mandatory recall.

Are there penalties for failing to conduct a mandatory recall?

Yes. The Act includes criminal offence and civil penalty provisions ranging up to 50,000 penalty units for non-compliance with requirements imposed to conduct a mandatory recall.

What's the best way to avoid having to undertake a mandated recall?

Follow the URPTG. We strongly encourage sponsors to continue working cooperatively with us in accordance with the URPTG in order to remove defective or unsafe goods from the market. This is the time proven, most optimal way to proceed in the interests of ensuring public health and safety.